CHIME Asks for More Time to Meet Stage 2 MU

May 9, 2012 – The College of Healthcare Information Management Executives (CHIME) submitted its comments on the proposed rules for Stage 2 Meaningful Use (MU), calling for more time to allow healthcare organizations to better prepare.

Comments filed with both the Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health IT (ONC) identified concerns related to the proposed Stage 2 electronic health record (EHR) reporting period as well as CMS’ varying approach to clinical quality measures (CQMs). CHIME also made recommendations on all 42 proposed objectives for eligible professionals (EPs), eligible hospitals (EHs) and critical access hospitals (CAHs).

CHIME recommended that CMS allow EPs, EHs and CAHs to demonstrate MU during a continuous 90-day EHR reporting period for their first payment year in Stage 2, mimicking the approach used in Stage 1.

“To allow adequate time for application development, provider adoption and testing, CMS should follow the precedent set in Stage 1,” CHIME said. “And similar to Stage 1, the EHR reporting period would be any continuous 90-day period within the first payment year ofStage 2 and a 365-day reporting period for all subsequent payment years within Stage 2.”

“We felt the approach taken in Stage 1 gave providers much-needed time to make sure the correct fields were populating and accurate Meaningful Use reports were being produced. We think a similar approach is needed for Stage 2 and beyond,” said Pam McNutt seniorvice president and chief information officer at Dallas-based Methodist Health System.

“While we appreciate the delay of Stage 2 to Fiscal Year 2014, that decision was necessary, given that no one would be in a position to meet Stage 2 requirements beginning Oct. 1, 2012,” added McNutt, a member of CHIME’s Policy Steering Committee. “By giving providers flexibility through a 90-day reporting window, CMS can ensure that more Stage 1 Meaningful Users will become Stage 2 Meaningful Users.”

In both letters, to CMS and ONC, CHIME commented on the challenges involved with clinical quality measures (CQMs). “The accurate reporting of quality measures is one of the most daunting challenges faced by providers today,” CHIME said. “Through our experiences with Stage 1, we found that although EHR products were able to automatically produce CQM reports, the data was inaccurate and largely incomparable across different providers.”

As part of Base EHR certification, CHIME urged ONC to require certification of EHR products to all CQMs needed to meet MU in each setting. CHIME wrote that “certification should include all CQMs for associated settings. And in order to minimize the costs of development and implementation, we recommend that ONC work with CMS to limit the total number of CQMs associated with each setting.”

“Quality measures are a vital component to increasing care efficiency, decreasing disparities and lowering costs,” said Elizabeth Johnson, vice president of applied clinical informatics at Tenet Healthcare and a member of CHIME’s Policy Steering Committee. “It is clear thatONC recognizes the value of quality measures, but the state of quality measurement needs to mature. HHS has been working to harmonize CQMs across its various reporting programs; however, more must be done to make the quality metrics consistent and meaningful.”

CHIME’s comments include suggestions on all 42 objectives and measures for both ambulatory and inpatient settings of care.

While CHIME supported nearly every measure meant to meet each objective, member CIOs were concerned with the lack and types of menu options for EPs, EHs and CAHs. “The menu set for both EPs and hospitals is quite small in relation to the minimum number thatwould need to be met, thereby providing relatively few options for EPs and hospitals,” the comment letter said. “A number of the proposed menu set objectives and measures also would have non-trivial cost implications for EPs and hospitals.” CHIME urged CMS to carefully assess both the number and feasibility of menu options for the average physician practice or the average hospital in finalizing its rule for Stage 2.